VAT-EU 2026
registration via VAT-R part C.3 — fields 58, 59, 60
Registration for VAT-EU is an obligation for every entrepreneur in Poland who carries out transactions with counterparties from other EU Member States — regardless of whether they are an active VAT payer or use the exemption. We explain how to properly complete part C.3 of the VAT-R form, which of the three paths to choose, and what value the NIP with the PL prefix brings.
What VAT-EU is and when you need the PL prefix
VAT-EU is not a separate tax — it is a special status that enables intra-EU transactions to be settled under the reverse-charge mechanism. After registration, you gain the right to use your existing NIP preceded by the prefix PL (e.g. PL5260250995).
The NIP-EU number is used for:
- Applying the 0% rate on intra-EU supply of goods (WDT),
- Settling intra-EU acquisition of goods (WNT),
- Supplying and acquiring services under art. 28b of the VAT Act (settlement on the buyer's side),
- Verification in the VIES system of the European Commission,
- Mandatory monthly filing of VAT-EU summary information.
The legal basis is art. 97 of the Polish VAT Act of 11 March 2004.
Who must register for VAT-EU
The registration obligation covers two groups of taxpayers:
1. Active VAT payers — before the first intra-EU transaction, that is:
- WDT — sale of goods to another EU country (with transport),
- WNT — purchase of goods from an EU counterparty,
- Supply of services to EU counterparties where the place of supply is the buyer's country (art. 28b),
- Acquisition of services from EU counterparties where the place of supply is Poland (art. 28b).
2. VAT-exempt taxpayers — in three situations:
- The annual value of WNT exceeded 50,000 PLN (or you anticipate exceeding it),
- You acquire services under art. 28b from an EU counterparty (e.g. IT, advisory, marketing services),
- You provide services under art. 28b to an EU taxpayer (e.g. a Polish freelance programmer for a German company).
VAT-exempt persons do not need to register for the sale of goods to EU individuals (B2C) — in that case the WSTO (intra-Community distance sales of goods) rules apply, with an annual threshold of 10,000 EUR.
Three registration paths — fields 58, 59, 60
Part C.3 of the VAT-R form contains three fields defining the registration path:
| Field | Status | What it covers |
|---|---|---|
| 58 | Active VAT payer | All intra-EU transactions (WDT, WNT, services 28b — purchase and sale) |
| 59 | VAT-exempt | WNT (after exceeding the 50,000 PLN limit or voluntarily before) |
| 60 | VAT-exempt | Import of services under art. 28b (acquisition of services from EU) or supply of services 28b to EU |
One taxpayer may tick several fields at once — for example, a VAT-exempt person performing both WNT (field 59) and acquiring services under art. 28b (field 60). An active VAT payer ticks only field 58 (covering all categories).
Field 68 — start date of intra-EU transactions: the date you plan your first transaction. After this date the tax office assigns you the PL prefix and adds you to the VIES system.
Field 58 in practice — active VAT payer
The most common scenario: an active VAT payer starting trade with EU counterparties. Examples:
Example 1. Andrzej runs a JDG in Poland selling furniture on Allegro. He receives an order from a Czech company with the active number CZ12345678. To apply the 0% WDT rate, he must before the shipment file VAT-R with field 58 ticked and the start date entered in field 68.
Example 2. A Sp. z o.o. imports electronic components from Germany. After VAT-EU registration it settles WNT in JPK_V7M under the reverse-charge mechanism — declaring output VAT and deducting it as input VAT in the same period (tax neutrality).
Example 3. Stanislav (foreigner with PESEL UKR, JDG active VAT) provides IT services to a Dutch company. Place of supply: the Netherlands (art. 28b). He issues an invoice without Polish VAT with the annotation "reverse charge" and reports the transaction in the VAT-EU summary information.
Fields 59 and 60 — when a VAT-exempt taxpayer must register
Contrary to popular belief, a VAT-exempt taxpayer also has a registration obligation in certain situations.
Field 59 — WNT by exempt persons: if your annual WNT turnover exceeds 50,000 PLN, you must register and tax purchases under the reverse-charge mechanism. You file declaration VAT-8 (instead of JPK_V7 for active payers) and pay VAT on WNT to the tax office account. Registration for VAT-EU does not cause loss of subjective VAT exemption for domestic sales.
Field 60 — import of services under art. 28b: if you buy digital services (Google Ads, Facebook Ads, Shopify, AWS, Mailchimp, SaaS tools), cloud hosting, or commissions from EU intermediaries — you must register. You file VAT-9M (declaration for the month in which the transaction occurred) and pay VAT.
Example. Marta runs a JDG, exempt from VAT (annual turnover 80,000 PLN). She buys Facebook ads for 3,000 PLN monthly (invoice from Ireland, IE9692928F). She must register for VAT-EU (field 60), file VAT-9M monthly, and pay 23% VAT on the net amount of the ads.
What happens after VAT-EU registration
After positive verification the tax office:
- Assigns the PL prefix to your NIP (e.g. PL5260250995),
- Enters you into the VIES database — from that point EU counterparties can verify you on the European Commission website,
- Imposes the obligation of monthly VAT-EU summary information (by the 25th day of the following month, electronically only).
Waiting time: usually 3-7 working days with electronic filing. After registration it is worth:
- Updating sales invoices (add the PL prefix to NIP),
- Notifying EU counterparties of your new NIP-EU number,
- Configuring accounting software to distinguish between domestic and intra-EU transactions.
Automatic deregistration from VAT-EU — the trap
The head of the tax office may deregister a taxpayer from the VAT-EU database ex officio if:
- For 3 consecutive months (or quarter) the taxpayer has not reported sales or purchases with VAT amounts in JPK_V7,
- For 3 consecutive months they have not submitted VAT-EU information despite the obligation.
Effect: loss of the PL prefix, inability to apply the 0% WDT rate, need to re-register. Only in the first case does the office notify the taxpayer of deregistration.
How to protect yourself: regularly check your status in VIES (once a month), even if you currently have no EU transactions. If you notice deregistration, immediately submit a new update VAT-R.
Specifics for foreigners — JDG with PESEL UKR / Karta Polaka
Foreigners running a JDG in Poland (based on PESEL UKR, Karta Polaka, permanent/temporary residence) register for VAT-EU on the same terms as Polish citizens. However, additional attachments to VAT-R are required:
- Copy of identity document (passport, Karta Polaka, PESEL UKR decision),
- CEIDG extract (JDG registration confirmation),
- Lease agreement or confirmation of address of residence in Poland.
At Księgowość 365 we serve Ukrainian, Belarusian and other foreign entrepreneurs registering a company in Poland — we prepare a full set of documents, fill in the VAT-R with C.3 fields, and represent you before the tax office.
Frequently asked questions
Do I have to register for VAT-EU if I sell on Allegro to consumers in Germany (B2C)?
No — sales to individuals from the EU (B2C) are governed by WSTO rules (intra-Community distance sales of goods). Up to a limit of 10,000 EUR per year, you settle in Poland with Polish VAT. After exceeding the limit, you either register for OSS or tax in the buyer's country. VAT-EU concerns B2B transactions (business-to-business) with the buyer's active NIP-EU.
Which NIP-EU number do I put on an invoice when selling to Germany?
Two numbers: your own (PL + 10 digits NIP) and the buyer's number (DE + 9 digits Umsatzsteuer-ID). The invoice must also contain the annotation 'WDT — 0% rate' and a confirmation of goods export (CMR, transport document).
Does VAT-EU registration cause loss of subjective VAT exemption?
No. VAT-EU registration is independent of domestic VAT status. You can be exempt from VAT on domestic sales (200,000 PLN limit) while being registered for VAT-EU for WNT or service imports. These are two different registers.
What if I forget to register for VAT-EU before the first WDT?
You lose the right to the 0% rate — the transaction is taxed in Poland at the domestic rate (23%). Additionally, the office may impose a sanction under art. 112c of the VAT Act (up to 100% of the underpaid tax amount). That is why VAT-R with field 58 is filed before the planned first delivery date.
How much does VAT-EU registration cost?
The registration itself is free — you just file VAT-R with part C.3 completed. If you outsource it to an accounting firm (e.g. Księgowość 365), the cost is around 150-300 PLN one-off, depending on complexity (e.g. foreigners with extra attachments).
Need help with VAT-EU registration?
We will check whether you are subject to mandatory VAT-EU registration, choose the correct field in VAT-R, and submit the declaration on your behalf. We will also advise how to organize WDT/WNT settlements, file VAT-EU summary information, and verify contractors in the VIES system.
For foreigners (PESEL UKR, Karta Polaka, residence permits) we prepare a full set of attachments and represent you before the Polish tax office.
Book a free consultation See services
Related articles
Anna specializes in VAT, KSeF, intra-EU transactions and e-commerce support for small and medium businesses in Poland.